Effective: May 1, 2020.
- INEO, Inc. is the data controller of your personal information.
- We collect the personal information set out in the "What Information We Collect" section of this Privacy Notice below, including account registration details such as name and email, details of Content Offerings you undertake, survey information (where you provide it), identity verification data, and information about your use of our site and Services.
- We use your personal information for the purposes set out in the "How We Use the Information" section of this Privacy Notice below, including providing our site and Services to you, ensuring the security and performance of our site, conducting research relating to Content Offerings, direct marketing, and performing statistical analysis of the use of our site and Services.
- You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the "Updating or Deleting Your Personally Identifiable Information" section of this Privacy Notice below.
Purpose And Who We Are
The purpose of this Privacy Notice is to describe how INEO, Inc. ("INEO," "us," "we," or "our") collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to cefeacademy.com and cefeonline.com (collectively referred to herein as the "Site").
Our Platform allows, any Client that uses it (our Clients and INEO itself) to build and manage training courses. This can include collecting contact information and other demographic information from Visitors or Clients who are participating in courses and trainings. INEO provides the Platform to our Clients to manage their courses or to find and attend courses, and we use it to run our Services.
What Information This Privacy Notice Covers
This Privacy Notice covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personally Identifiable Information, though for features or Services related to the Content Offerings, Personally Identifiable Information is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, "Personally Identifiable Information" (i.e., information that can be used to identify you)(may also be referred to as “personal data” or “personal information”).
Personally, Identifiable Information can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to INEO. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What You Agree To By Using Our Site
We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Site and provide our Services;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
- consent, to send you certain communications or where you submit certain information to us.
Which legal basis applies to a specific processing activity will depend on the type of personal information processed and the context in which it is processed.
If we rely on our legitimate interests for using your personal information, we will undertake a balancing test to ensure that our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our Services to you.
What Information We Collect
We gather two types of information about users through the Site:
- Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other INEO events, and send you email messages about Site maintenance or updates.
- Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address.
- Updates. INEO may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personally Identifiable Information such as your name and email address.
- Participation in Content Offerings. INEO offers users the opportunity to participate in an “Content Offerings” on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.
If you participate in a Content Offering, we may collect from you, certain participant-generated content, such as assignments you submit to trainers and instructors, peer-graded assignments, and peer grading participant feedback. We also collect course data, such as participant responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.
- Identity Verification. INEO may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document.
- Communications with INEO. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
- Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third-party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third-party site.
- Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us or a Content Provider.
- Partner sites. Partner sites providing Content Offering related tools and services to INEO users may collect nonfinancial individual level user data regarding the individual’s use of that partner site while the partner sites provide those services to INEO. The partner sites may share that data with INEO for the purpose of improving INEO’s Services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.
- Third Party Credit Card Processing. INEO provides you with the ability to pay for Content Offerings and other Services using a credit card through a third-party payment processing service provider. Please note that our service provider – not INEO – collects and processes your credit card information.
How We Use The Information
- Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.
- Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Notice or as specifically agreed to by you, INEO will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Notice, we may disclose and otherwise use Personally Identifiable Information as described below.
- TECHNICAL SUPPORT AND SECURITY. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our Services and the Site.
- UPDATES. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- FORUMS. You should not post any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post Personally Identifiable Information, such Personally Identifiable Information may be collected during your use of the Forums. We may publish this information via extensions of our Platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain Personally Identifiable Information in future versions of the Content Offerings, and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partner, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.
- PARTICIPATION IN CONTENT OFFERINGS. We use the Personally Identifiable Information that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- IDENTITY VERIFICATION. For Services that require identity verification, we may use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This Service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
- COMMUNICATIONS WITH OR FROM INEO. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
- COMMUNICATIONS WITH INEO BUSINESS PARTNERS. We may share your Personally Identifiable Information with Content Providers and other business partners of INEO so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- RESEARCH. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.
- DISCLOSURE TO INEO OPERATIONS AND MAINTENANCE CONTRACTORS. We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our Services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personally Identifiable Information by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
- DISCLOSURE TO ACQUIRERS. INEO may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of INEO to which your Personally Identifiable Information relates.
Log Files And Retention Of Personally Identifiable Information
INEO may collect demographic information, such as your ZIP code, age, gender, preferences, interests and favorites using log files. There may also be information about your computer hardware and software that is automatically collected by us. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by INEO for the operation of the Platform, to maintain its quality and to provide general statistics regarding use of the Platform. For these purposes, INEO may links this automatically-collected data to personal information such as name, email address, address, and phone number.
YOUR PRIVACY CLASSIFICATION This policy classifies those accessing and using our Services as one of the following:
VISITORS: Individuals and entities that access and interact with our Websites (for instance, to read about INEO products and services, downloads), as well as those whom we meet or learn about through referral, from third parties or other external sources, are referred to as “Website Visitors” or simply “Visitors”. Personally identifiable information pertaining to Visitors subject to this policy is maintained in one or more INEO databases and Website analytics and management systems where Platform end-user information is maintained.
CLIENTS: Individuals and entities that are INEO’s direct clients (for example, service creators), including individuals attending INEO courses and trainings, as well as client personnel that are assigned a login ID and are authorized to access and use our Platform pursuant to an active INEO agreement or under a temporary evaluation license if available, are referred to as “Clients.” Personally identifiable information of Client personnel associated with their Platform accounts is treated as End-User information, and will not be used for any purpose other than providing and supporting our Platform.
END-USERS: Clients’ business contacts, which may include their own current and prospective clients, members, partners, or other third-party contacts that use our Platform to interact with our Clients (for example, individuals that register for an event organized by a Client, download an event-related mobile app) are referred to as “Platform End-Users” or simply “End-Users.” INEO does not use personally identifiable information of End-Users for any purpose other than providing and supporting the Platform.
We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is collected and processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
COOKIES AND SIMILAR TECHNOLOGIES
• Session Cookies and Persistent Cookies. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted. A persistent cookie will be reactivated when a user returns to the website which posted the cookie. Cookies cannot read or access other cookies or any data from a user’s hard drive. Cookies alone will not personally identify a user; however, a cookie may recognize a user’s individual web browser or device through an IP Address, browser version, operating system and other information, and End users of our Services who log into their INEO accounts may be individually identifiable to particular Services using session cookies.
• Flash Cookies. Certain features of our Services may use local storage, such as “Flash cookies” to collect and store information about your preferences and navigation to, from and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages on our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs). Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email. Web beacons permit us to track online movements of web users – for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). This enables INEO to provide a website experience more tailored to your preferences and interests.
• Log files: For technical reasons (security reasons and protection of our Website), INEO collects server log data which are received from your browser. The log data are deleted after 14 days.
• Advertising and analytics. When you access and use the Services and other websites, we or a third-party partner may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our Clients) based on information relating to your access to and use of the Services and other websites. To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies).
• We also may use information associated with Visitor social media accounts.
Confidentiality & Security Of Personally Identifiable Information
We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.
Updating Or Deleting Your Personally Identifiable Information
You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the Site and visiting your user account page.
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
• Tracking Technologies and Advertising. You may set your web browser to restrict or to entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device. Visitors who block cookies may be able to access a Website but will not be able to use most of the content, Platform and services available on that site. Limiting or restricting certain types of cookies may also prevent a Client or End-User from using certain portions of the Platform, depending on how the browser settings are configured.
• Promotional Offers from INEO. If you do not wish INEO to use your contact details to send you promotional messages, or would like us to prevent a Client from using the Platform to send you emails to promote its own or third parties’ products or services, you can (i) adjust your email preferences on the profile page, or (ii) at any other time by sending an email stating your request to us. We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you, as a Website Visitor or Client, opt-out of receiving marketing-related emails from us (or as an End-User opt-out of receiving marketing-related emails from one of our Clients), we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
ACCESSING AND CORRECTING YOUR INFORMATION
Upon request, INEO will provide you with information about whether we hold any of your Personal Information. If you are a registered user of one of our Services, you can review, request deletion, and change your Personal Information by logging into the Services and visiting your account profile page. For example:
• Users of our Platform may update or correct their Personal Information, other profile settings and user preferences.
• Users who have opted to join an event attendee list (visible to other users for that event) may have the option to later hide themselves from the list if desired.
• You may also send us an e-mail to request access to, correct or delete any Personal Information that you have provided to us. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will respond to your request within a reasonable timeframe. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
CHILDREN UNDER THE AGE OF 14
Our Services are not intended for children under 14 years of age. We do not directly solicit or collect Personal Information from children under 14. If you are under 14, do not (i) use or provide any information on these Services or on or through any of its features, (ii) register to use any of our Services, (iii) make any purchases through our Services, (iv) use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.
CROSS-BORDER TRANSFERS (OTHER THAN TO THE E.U.)
Although Services are controlled and operated by us from Tunisia, by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country, if we need such third country contractors to fulfil our contractual duties.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
INFORMATION COLLECTED ON BEHALF OF OUR CLIENTS
INEO collects information under the direction of its clients and has no direct relationship with the End-User individuals whose Personal Information it processes. If you are an End-User of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly. We may transfer Personal Information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Clients. Please note that Clients may have their own / additional Terms and Services, which you have to comply with.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to INEO’s Client (i.e., the data controller). If requested to remove Personal Information we will respond within a reasonable timeframe.
We will retain Personal Information we process on behalf of our Clients for as long as needed to provide services to our Client. INEO will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Changing Our Privacy Notice
Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Notice by posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your user account, and by changing the effective date (located at the top and bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Notice.
Questions, Suggestions, And Complaints
You have at any time the right to revoke your consent to the use of your personal data. Your request for information, deletion, correction, or data transfer, unless this is a disproportionate effort, shall be addressed to us immediately. We will be happy assisting you with your query.”
To contact INEO Inc, please use the following contact info:
Post: INEO Inc, : 97 Avenue F. Hached Kalaa Sghira 4021 Tunisia Phone: +216 98 240 781